INDICTMENT

The Grand Jury charges that:

COUNT ONE

Introduction

1. The District of Columbia Taxicab Commission ("DCTC")
regulates the operation of taxicabs in Washington, D.C. The DCTC, among
other things, establishes criteria, standards, and requirements for
taxicab licensing, including the licensing of owners, operators,
companies, associations, and fleets. It also sets licensing fees. The
DCTC comprises seven commissioners and a chair.

2. In order to be licensed to operate a taxicab in the
District of Columbia, one must do the following: (1) successfully
complete a course offered at the University of the District of Columbia,
which includes a test; (2) pass the DCTC's hack test; and (3) pass
medical and criminal checks.

3. Public Official Number One became chairperson of the
DCTC on or about July 7, 2007. As part of his official duties, Public
Official Number One (the "Chairperson") performed the
following acts among others:

(a) the Chairperson had authority and
influence over the issuance of licenses to operate multi-vehicle taxicab
companies in the District of Columbia;

(b) the Chairperson had authority and
influence over the issuance of individual District of Columbia taxicab operator licenses which,
when issued, authorized individuals to operate taxicabs in the
District of Columbia;

(c) the Chairperson could recommend to
the Council of the District of Columbia and

(d) the Chairperson could present positions to the
Council of the District of Columbia and others in opposition to proposed
legislation affecting the taxicab industry in Washington, D.C.

The Conspiracy

6. From between on or about September 3, 2009, until on
or about September 28, 2009, the exact dates being unknown to the grand
jury, in the District of Columbia and elsewhere, defendants DAGMAWI
TEFERA AMANUEL, SURAPHEL AYALEW, MEKWANINT ABEBE AYELE, SOLOMON TAMEGN
AYELA, IYASU BAZEZEW, DEREJE TAYE DEJENE, AMBACHEW A. DEMSSIE, BIRHANU
SHOA GEBREGZIABHER, DEREGE GEMECHU, TURA BURKA GEMEDA, ERMIAS ASFAW
GETACHEW, SALAHADIN ABUBEKER HAGOS, BAHIRU GETACHEW HAILEGEBREAL,
TADESSE MAMO HAILEYESSUS, OMAR H. HASSEN, MICHAEL MOLLA HUNACHEW, ISHAQ
SANI HUSSEN, OMAR M. HUSSEN, ABUDAWOD AL! HUSSIEN, NEBIL MUSTEFA ISMAEL,
GEORGE SEYOUM KEBEDE, ABBA-YOHANNES DETAMO LAILAGO, ASHENAFI TEFERA
METAW, FEYSAL JEMAL MOHAMED, ISMAEL OMDURMAN, ETANA ENGEDA SHUREMU,
YITBAREK SYUME, YONAS TADESSE, ESMAEL ABDULBASIT TAHIR, ZELALEM ABABU
TAREKEJN, DULA TILAHUN, FASIL REGASSA WAKJIRA, DANIEL WOLDETENSAY, YOHANNES GURMU WONDIMU, ASHENAFI
TESFAYE WORKU, ABEBAW NIGUSSIE YEHUALA, and AMEZENE A. ZEWDIE (the
"DEFENDANTS"), and others known and unknown to the Grand Jury,
knowingly and willfully conspired and agreed together and with each
other, and with other persons both known and unknown to the grand jury,
to commit the following offense against the United States: that is to
directly and indirectly, corruptly give, offer, and promise things of
value to the Chairperson, with intent to influence official acts, that
is the DEFENDANTS agreed to give cash in various amounts to the
Chairperson in return for his agreement to issue taxicab operator
licenses to the DEFENDANTS, in violation of Title 18, United States
Code, Section 201(b) (Bribery of a Public Official).

A Goal of the Conspiracy

7. It was a goal of the conspiracy to
obtain corruptly and illegally licenses to operate taxicabs in the
District of Columbia from the Chairperson in exchange for cash.

Manner and Means of the Conspiracy

8. The DEFENDANTS and other unindicted
coconspirators, both known and unknown to the Grand Jury, used the
following manner and means among others to accomplish the object of the
conspiracy:

(a) It was part of the conspiracy that the DEFENDANTS
would and did play different roles in the conspiracy, and took upon
themselves different tasks and participated in the conduct of the
organization through various criminal acts. The DEFENDANTS made
themselves and their services available at various times throughout the
life of the conspiracy and participated in activities required to obtain
corruptly licenses to operate taxicabs in the District of Columbia. Some
of the roles assumed and carried out by YITBAREK SYUME and SURAPHEL AYALEW and other
unindicted coconspirators both known and unknown to the grand jury
included, among others, recruiting and organizing co-conspirators who
wanted to obtain corruptly taxicab operator licenses; collecting
approximately $110,000 in cash to be used for bribe payments to the
Chairperson; and instructing co-conspirators as to when, where, and how
cash payments should be made to the Chairperson.

(b) It was further part of the conspiracy that YITBAREK
SYUME and SURAPHEL AYALEW collected and forwarded to the Chairperson
applications of coconspirators who wanted to obtain corruptly taxicab
operators licenses.

(c) It was further part of the conspiracy that the
DEFENDANTS met the Chairperson to provide fingerprints and photographs
in conjunction with attempting to obtain corruptly taxicab operator
licenses, at which time they also paid cash to the Chairperson for the
operator licenses.

Overt Acts

9. In furtherance of the conspiracy and
in order to achieve the goals thereof, the DEFENDANTS and others, known
and unknown to the grand jury, within the District of Columbia, and
elsewhere, committed overt acts, including, but not limited to the
following:

(1) On or about September 3, 2009, YITBAREK SYUME and
SURAPHEL AYALEW met the Chairperson, at which time they discussed
the method by which they would obtain corruptly taxicab operator
licences, including the preparation of applications, the location for
meetings, and the amount of the bribes to be paid to the Chairperson.

(3) On or about September 18, 2009, YITBAREK SYUME gave the
Chairperson approximately $51,000 in cash as partial payment for
taxicab operator licenses that he and the other co-conspirators were
attempting to obtain corruptly.

(4) On or about September 18, 2009, YITBAREK SYUME,
DEREGE GEMECHU, ERMIAS ASFAW GETACHEW, SALAHADIN ABUBEKER HAGOS, YONAS
TADESSE, AMEZENE A. ZEWDIE, BIRHANU SHOA GEBREGZIABHER, DEREJETAYE
DEJENE, DAGMAWI TEFERA AMANUEL, ASHENAFI TESFAYE WORKU, OMAR M. HUSSEN,
and GEORGE SEYOUM KEBEDE met the Chairperson, at which time they paid
cash to him for the taxicab operator licenses that they were attempting
to obtain corruptly,

(6) On or about September 21, 2009,
YITBAREK SYUME gave the Chairperson approximately $40,000 in cash as
partial payment for taxicab operator licenses that he and the other
co-conspirators were attempting to obtain corruptly.

(7) On or about September 27, 2009, SURAPHEL AYALEW met
the Chairperson at which time he discussed the logistics for the receipt
of taxicab operator licenses by himself and the other co-conspirators.

(8) On or about September 28, 2009,
YITBAREK SPUME met the Chairperson at which time he discussed the
logistics for the receipt of taxicab operator licences by himself and
the other co-conspirators.

(Conspiracy to Commit Bribery, Aiding and Abetting,
Causing an Act to be Done, in violation of Title 18, United States Code,
Sections 371 and 2)

A TRUE BILL:

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FOREPERSON

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Acting United State Attorney of the United States in and for the
District of Columbia